LAW

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KembaraXtra-Case Law-Brooks and Brooks (1982) - Theft Act 1978, s.3
​I. Facts of the Case
  • Defendants (D1 & D2) dined with S at a restaurant.
  • D1 left abruptly.
  • Manager discovered S in the toilet and D2 attempting to leave.
  • D2 was apprehended by the manager.
  • Both defendants charged under s.3 of the Theft Act 1978.
II. Legal Issue
  • Interpretation of "dishonestly makes off" under s.3 Theft Act 1978.
  • Distinction between the complete offence and an attempt to commit the offence.
III. Held
  • "Dishonestly makes off" should be given its ordinary meaning, related to the specific facts.
  • "Making off" requires departure from the point where payment is required.
  • If D is stopped before passing the payment point:
    • Jury should be directed that this may be an attemptnot the completed offence.
    • Subject to evidence that other elements of an attempt are present.
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